As an LMHP responsible for implementing this policy, I cannot comply with both its clinical requirements and its mandated accreditation standards without creating an operational conflict with my professional obligations.
I am a Licensed Clinical Social Worker co-supervising a psychosocial rehabilitation program serving individuals with serious mental illness, including individuals with high-risk histories and NGRI status. I submit this comment to place on record that the requirements described in the draft manual, when implemented alongside Clubhouse International accreditation standards, create a structural conflict in practice for licensed clinicians. I am concurrently submitting a formal request for advisory guidance to the Virginia Board of Social Work regarding my professional obligations under this framework.
The draft manual establishes a service model requiring LMHP oversight, clinical assessment, individualized service planning, rehabilitative intervention, and crisis support. These requirements reflect a clinically defined service structure.
However, when implemented alongside Clubhouse International accreditation standards, an operational and professional conflict emerges for LMHPs.
Clubhouse International explicitly states that “the role of the staff in a Clubhouse is not to educate or treat the members” (Source: https://clubhouse-intl.org/what-we-do/what-clubhouses-do/). This reflects a non-clinical service model.
In practice, these requirements establish divergent expectations:
DMAS requires LMHP-directed clinical oversight, assessment, and intervention
Clubhouse accreditation requires a non-clinical environment in which staff do not provide treatment or educational services
When applied simultaneously, these frameworks impose conflicting operational requirements regarding the role of staff, the scope of supervision, and the permissible nature of clinical engagement.
Licensed Clinical Social Workers in Virginia are bound by 18VAC140-20-150, which establishes that:
Protection of public health, safety, and welfare is the primary professional obligation (A)
Practice must be consistent with professional standards and within the boundaries of competence (B)(1), (B)(3)
Virginia’s standard of care statute (Va. Code § 8.01-581.20) further establishes that clinicians are held to the level of care exercised by a reasonably prudent practitioner under similar circumstances. This obligation is independent of program structure or funding mechanism.
Together, these requirements obligate LMHPs to exercise clinical judgment and respond appropriately when clinical need is identified within their scope of competence.
DMAS requires clinical supervision and individualized clinical oversight within this service model. Clubhouse accreditation standards, specifically Standard 8, do not contemplate or support clinical supervision structures that involve treatment-oriented case formulation or intervention planning (Source: https://clubhouse-intl.org/wp-content/uploads/2025/11/Standards_2025_english.pdf).
As implemented, this produces an operational conflict in which compliance with accreditation requirements constrains the clinical functions that DMAS simultaneously requires under LMHP-level service delivery.
This is not theoretical. It is a structural implementation conflict that emerges in practice under dual compliance requirements.
My obligations as a licensed clinician are defined by Virginia law and professional regulation. They are not modified by program designation or accreditation requirements.
When a service model requires compliance with accreditation standards that constrain clinically indicated practice, while simultaneously requiring LMHP-level clinical oversight, it creates a structural conflict in implementation that cannot be resolved at the individual clinician level.
This also creates a conflict between required accreditation attestation and the actual clinical conditions under which services are delivered. Licensed professionals are placed in a position where attesting to compliance with external accreditation standards are not reconcilable with the requirements of professional licensure and the real-world execution of clinical duties.
Based on the structural and professional conflict outlined above, I request that DMAS reevaluate compatibility of mandated Clubhouse accreditation requirements with LMHP clinical practice obligations under Virginia law, and consider the material impact of this framework on licensed clinicians who are ethically and legally responsible for its implementation in real-world service settings.